12VAC5-590-600. D. Cross Connection Control Program Responsibilities.

The James City Service Authority is concerned about this paragraph.  Irrigation systems are high hazards – period.  They are exposed to everything in or on the ground to include insects, animal feces, animal urine, and other chemical and biological contaminants.  They also may be subject to various onsite conditions such as additional water supplies, booster pumps, and elevation changes.  In addition, many are used to feed highly toxic fertilizers, herbicides, and pesticides.  In most instances, without the consent or knowledge of the water system owner.  These systems are required to have a backflow prevention assembly (BPA) for a reason - because they are a high hazard.  They have been identified as such by the Virginia Department of Health (VDH) for nearly 40 years.  The hazard an irrigation system presents to the waterworks doesn’t change based on whether it is zoned commercial or residential.  Given the fact that they are clearly identified as a high hazard, this section, or any other section in these regulations should not be allowed to substitute a public education system for the required testing of irrigation system BPA’s.  The safety of the consumer should be paramount, regardless of staffing requirements.  How much will it cost if one or more of these chemicals are back-flowed into one of our distribution systems?  If, for the sake of argument, cost is a consideration for some municipalities, then we would point out the many companies that offer programs that can manage and track their cross connection control program with little, or even no cost for the municipality.   

To conclude, it’s an unfortunate fact that water distribution systems experience breaks on a somewhat frequent basis.  When these breaks occur, it is a fair assumption that in many of these cases water is being back-siphoned back into our distribution systems.  It is an undeniable fact.  These breaks do not only occur on water lines serving commercial properties.  Do we want to hope that the irrigation systems hazards noted above are being controlled because we sent the irrigation system owner an educational letter, or know we are protected because we ensured they were tested each year?  Educational programs are a great way to enlighten consumers about the potential hazards associated with cross connections for properties that are without any known high hazards.  An irrigation system simply does not fall into that category.  The original regulations required that they be tested and tracked annually.  There was a Working Memo (WM801) developed by the VDH that required that they be tested and tracked annually.  If we want to keep our distribution systems safe, we should ensure that they continue to be tested and tracked at least annually.  We suggest it be changed to read:

D. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner may provide a public education program to residential and commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in 12VAC5-590-610 C. through 12VAC5-590-610 E. or Table 630.1.   

12VAC5-590-610. E. Containment of backflow.

The James City Service Authority is concerned about this section.  Item 11 as written can leave potential hazardous situations as not requiring adequate protection.  We suggest it be changed to state:

Item 11.  Buildings with commercial, mixed use, industrial, or institutional occupants served through a master meter.

Additionally, the proposed wording at item 21 is not as concise as it was under the original regulation.  The pressure created through elevation does not change for buildings above 3 stories based on the classification of use.  The concerning backpressure that can be created is the same no matter what type of building it is.  The proposed wording can create future loopholes in the requirement.  We suggest to leave it as it is currently written in the existing cross connection regulations:

Item 21. Highrise buildings (four or more stories).

12VAC5-590-630 B.3. Backflow prevention assemblies, devices, and backflow elimination methods for containment.

The James City Service Authority is concerned about this paragraph. The protection of our water distribution systems should be of the highest priority.  As such, we should want to ensure that the assemblies we utilize meet the highest quality approval standards.  No other approval listing meets the standards as set forth by the University of Southern California’s Foundation for Cross Connection Control and Hydraulic Research (USC CCC&FHR).  Their rigorous testing program emphasizes what is the most important aspect of the BPA’s we select to protect our water systems – does it actually work as it is designed under all possibilities of conditions and usage.  AT the USC CCC&FHR the various sized BPA’s are tested at various temperatures, pressures, and orientations.  Most importantly they are field tested for one year so that we can be assured that it will continue to function properly over an extended time frame, and under the harsh field conditions that they are subject to be exposed to.  It is under this final stage of field testing that upwards of thirty percent of the submitted BPA’s fail to meet the standards.  Since after the initial installation, or after repairs or relocation, we only require our BPA’s be tested annually, shouldn’t we want to have a containment BPA that has met this criteria?  The VDH developed a Working Memo (WM801) that required this designation for our containment assembly.  It stated:

Approved Containment Devices. Containment devices under the jurisdiction of the Waterworks Regulations (12 VAC 5-590-620) are those which meet AWWA standards, hold ASSE approval, and have an approval from the University of Southern California Foundation for Cross Connection Control and Hydraulic Research (USC). USC Foundation members are kept up to date on approvals. Otherwise, the supplier or manufacturer can supply approval documentation. NOTE: USC device approval is specific to orientation, horizontal or vertical, device model number and size. Approvals are continuously verified and can be rescinded.

The USC CCC&FHR no longer requires membership to access their approved listings, and it is a valuable tool that is available for all to utilize.  We suggest the standard that was set by the VDH in its WM801 be similarly transferred to replace the current wording:

12VAC5-590-630 B. 3. Containment devices under the jurisdiction of the Waterworks Regulations are those which meet AWWA standards, hold ASSE approval, and have an approval from the University of Southern California Foundation for Cross Connection Control and Hydraulic Research (USC).  NOTE:  USC device approval is specific to orientation, horizontal and vertical, device model, number and size.  Approvals are continuously verified and can be rescinded.